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Madison-Kipp Corp.

Madison-Kipp Corp. is a century-old aluminum and zinc die cast factory located in the Atwood neighborhood of Madison, Wisc. The factory is adjacent to homes, a community center, food gardens and 200 feet from an elementary school. With abutting property lines, many houses are within 50 feet of the actual factory. Pollutants include PCBs, dioxins, PCE, TCE, vinyl chloride, heavy metals along with many greenhouse gases. Dr. Lorne G. Everett, an international hydrogeology expert who has investigated hundreds of contaminated sites worldwide, calls Kipp “one of the most contaminated sites that I’ve ever worked with.”

Is Kipp A Safe Place to Work? Cleaning Employee Fired by Contractor for Asking

Is Kipp A Safe Place to Work? Cleaning Employee Fired by Contractor for Asking

(Madison-Kipp Worker Pouring Molten Aluminum)

–Madison Kipp Corporation’s non-unionized manufacturing workers, and contractors brought in to clean and do other work at the factory, are at ground zero for exposures to myriad toxic chemicals emitted in aluminum die casting processes, vapors from the giant plume of toxic volatile organic compounds (VOCs) beneath the plant, and polychlorinated biphenyls (PCBs) contaminated soils being excavated all over the site. See previous posts for more background.

Yet Kipp’s CEO Tony Koblinski assured people in a community presentation on March 19 2014 that Kipp has “good people and good jobs” and is “a company in control.” [1] Further, he asserted “people like working at Kipp, they always have.”

Kipp workers we have talked to over the years do indeed seem like good people, but the stories they told us about working there are not about “good jobs” in a factory that is “in control.” Those we have talked to—usually after they quit—not only did not like working at Kipp, but they did not feel safe or healthy there.

Our review of records, in fact, shows that Kipp’s manufacturing workers and contractors have very legitimate reasons to be concerned about their health and safety. Madison Fire Department (MFD) and Occupational Safety and Health Administration (OSHA) records on Kipp from 1990 to the present indicate that the place is anything but safe for workers. From 1998 through Feb. 2014, Madison Fire Department/Emergency Medical Services (EMS) paid approximately 172 visits to the Kipp facilities on Waubesa and Atwood Ave.[2] [3] Disturbingly, well over half of these calls—we counted 113—were “emergency medical service” (EMS) calls for worker injuries and/or health problems. Some reasons for EMS calls:  chest pains, difficulty breathing, dizziness, possible heart attacks or seizures, passing out from heat, low blood pressure/fainting, lacerations/loss of blood, finger amputations, fingers caught in machines, molten metal burns, burns from propane explosion, worker hit or pinned by forklift, hit over the head, falls, sprains, and more. The first two—chest pains and breathing problems—were listed many times. Either Kipp workers are not very healthy people to begin with, or something in the facility is causing these frequent health problems—or both.[4]

Since 1990, the facility has had numerous molten metal spills, explosions, and fires—most caused by ignition of highly combustible metal dusts and filings. In addition to being obvious immediate threats to worker safety, smoke and fumes from fires and materials used to extinguish fires are often toxic and associated with respiratory problems, cancer and other long-term health problems.[5]  Kipp’s MFD and OSHA records also raise serious questions about how prepared residents near the factory, and staff at Goodman Community Center and Lowell School, are for a chlorine or other chemical accident at Kipp (or an accident involving a truck transporting chemicals to/from there on roads in the neighborhood). For more info, see here.

Cleaning worker is fired for asking if Kipp is safe, requesting not to work there

In February 2014, a worker with existing respiratory problems, who had cleaned for the company Environment Control for five years, contacted MEJO about having headaches and respiratory problems when cleaning at Kipp (which he had recently been assigned to). Several employees of this company who had cleaned at Kipp before him had already quit because they did not want to work in the foundry. He asked his managers that he be transferred to another cleaning job, but they said he would have to prove that the factory was not safe before they would take him off the Kipp job (how could a worker possibly do this?). They told him if he had a health evaluation by a doctor, validating his respiratory problems and connecting them to exposures at Kipp, they might transfer him. Not having health insurance, he could not afford to see a doctor.

He began to search for information about the kinds of toxic contaminants he might be exposed to at Kipp, and sent documents he found (including some written by top scientific experts on the kinds of contaminants found at Kipp) to his managers. Unwilling to read or believe the information he provided, they continued to refute his concerns and demand that he continue cleaning at Kipp (several hours a night, five nights a week).

Frustrated, he eventually contacted MEJO with questions. He suspected that what he was breathing in Kipp was aggravating his lungs and causing headaches. Also, he recalled that for 2-3 weeks in Jan/Feb., while PCB contaminated concrete and soils (again, see this story) were being excavated to install new machines, piles of dirt were sitting all over on the factory floor.[6] Was anything done to reduce/eliminate PCB dust levels in factory air, to protect all workers in the plant? Were workers informed of the contamination? Did they have protective gear?[7]  According to the worker, no, no, and no.[8]

He said practices in the factory seemed very sloppy.  One day while cleaning he noticed a sign in the factory that said “number of days since last accident.” The number there that day was “10.” Factory workers told him 10 days without an accident “is pretty good for Kipp.” This is a factory that is “in control”? Hmmm….

When queried, Kipp assured managers at Environment Control that the factory was perfectly safe. Kipp presented the company with a document (apparently written by Kipp’s insurance company) stating that Kipp is safe.[9]  Rather than showing concern for their employee’s health, and considering the legitimate evidence he brought forward, Environment Control managers chose to believe whatever evidence Kipp and their insurance company gave them.[10]

Sadly, in late March, after continuing to request that he not work at Kipp, the cleaning worker was fired. Apparently Environmental Control considers its employees expendable.

Kipp workers, neighbors, and others have complained of health problems for decades

Many former Kipp workers have shared stories of disturbing health and safety problems in the factory over the years. In 1996, a person who worked at Kipp through 1989 (but believed that the conditions there remained unsafe or got worse after that) wrote a summary of some of the unhealthy conditions in the factory and environmental problems. Another former worker said that there were cases in which workers collapsed from fumes.

Kipp workers aren’t the only ones who have experienced health problems at Kipp. In July 1994, a DNR employee, investigating an odor complaint submitted by a neighbor, smelled a “metallic, solvent-like odor.” Her official statement about this incident says that within five minutes of leaving the plant after the investigation: “I experienced a dizzy, woozy feeling. My face and fingers felt numb and tingly, my heart was pounding, and I found my breathing rapid and shallow. My proprioreception was disrupted and I did not believe I could safely drive.”

In the last few years, there have been similar odd cases of people suddenly suffering health effects near Kipp.  In 2009, the Fire Department responded to situation in which a 10-year old child walking back from a school field trip felt faint and laid down on the grass on Atwood Avenue in front of the Kipp factory (it is unclear whether this incident was connected to any Kipp emissions—but it raises questions). In 2012, a bicyclist was riding on the bike path behind the Atwood plant, smelled a noxious odor that he connected with Kipp, and became nauseous.

Hundreds of reports have been submitted to local agencies over the last two decades by residents in the neighborhood about noxious smells from Kipp—especially the smell of chlorine and/or a “waxy/oily/burnt” smell. According to a 2001 report, “Evaluation of Community Exposure to Emissions from Madison Kipp Corporation,” people “identified both of these odors as the cause of acute illness including asthma attacks, sore throat, nausea vomiting etc.” and goes on to say “it is reasonable to assume that reports of chlorine odors originate from the aluminum melting and drossing process” and “emission of chlorine from this process is the most likely source of these odor complaints.” It also notes that “waxy/oily/burnt” smell in the neighborhood is from the die casting process but that “the chemical composition of this odor is unknown.”

Odor complaints have continued in recent years.[11] In early 2013, a resident on S. Marquette St., next to Kipp, emailed public health agency staff saying that 5 or 6 times in the last several years, he and his wife had “noticed the strong smell of burning rubber or plastic emitting from the basement stairs in our home,” particularly after heavy rainstorms or large snow melt-off events.” He noted that the smell “is not dissimilar to one of the odors that we occasionally smell outdoors and that the neighborhood generally associates with MKC.” He recalled a day in late 2012 in which “several in our neighborhood reported smelling a chlorine smell coming from the MKC property,” and he personally detected a “fairly strong burning rubber smell outdoors.”

Despite all of these worker and neighborhood complaints over the years, public health agencies have insisted many times that there are no harmful exposures in the neighborhood around Kipp—even while admitting many times in the 2001 report that there is not enough data to make this determination. As we described in previous articles (see here and here), a group of citizens from the community worked with government health agencies for nearly two years to develop a health study in the Kipp area, but the study was eventually dropped, for reasons that are unclear. Many suspect that Kipp played a role in shutting the study down.

Meanwhile, none of the DNR or public health agency reports, documents, or communications to date (we have reviewed thousands of pages of them) have even mentioned, let alone expressed concern about, potential exposures to workers inside the plant. Apparently manufacturing workers, most of whom are citizens of Madison and Dane County, are not included in their definition of “public health.”

Many respiratory irritants and toxins emitted in aluminum die casting facilities…

The fired cleaning worker’s aggravated respiratory symptoms and headaches in the factory parallel Madison Fire Department visits to the factory to attend to workers with chest pains, breathing problems, dizziness, and related symptoms. Moreover, Kipp’s terrible worker health, safety and OSHA records indicate that Kipp is doing far from an adequate job inside the factory protecting their workers from exposures to harmful chemicals, regardless of whether or not they meet standards (which is unknown, due to lack of adequate data). Many existing workplace health standards, heavily influenced by industry lobbying, are known to be far too lax and not adequate to protect workers’ health.

What are Kipp’s workers exposed to?  Releases from Kipp’s stacks aren’t all the same as what’s in factory air, but can tell us something about what chemicals the facility uses and emits into factory air.

As of 2004, EPA’s Toxics Release Inventory (TRI) listed the following as top air releases in aluminum die casting industries all over the U.S: aluminum (fume or dust), trichloroethylene, tetrachloroethylene, zinc (fume or dust), zinc compounds, copper, hexachloroethane, glycol ethers.[12] Unfortunately, it is increasingly difficult to find out what comes out of Madison-Kipp stacks in particular—in part due to industry’s political lobbying to keep this information out of the public realm, inadequate monitoring and lax regulatory approaches [13] .  Madison-Kipp’s 2012 DNR Air Emissions Inventory Report lists the following emissions: carbon monoxide, nitrogen oxides, particulate matter, hydrogen chloride, and “reactive organic gas” or ROG (otherwise known as volatile organic chemicals or VOCs). Many of Kipp’s most toxic emissions, however, are not reported on Kipp’s air inventories—or were in the past but are no longer .[14] [15] [16]  For instance, Kipp also emits dioxins and furans (among the most toxic compounds ever studied), aluminum salts, fluorides, fluorinated compounds, chlorine, chlorinated and chlorofluorinated compounds, numerous metals, polycyclic aromatic hydrocarbons (PAHs), and several other toxic compounds that are not listed on the inventories.

Just as problematically, the chemical composition of emissions from Kipp’s die casting processes—which include reactive organic gases (ROGs), polycyclic aromatic hydrocarbons (PAHs), small particulates, metals, and a mix of other contaminants found in oil mists associated with metalworking fluids used as die lubricants (discussed in more detail later)—have never been assessed.[17] The “emissions factors” used to assess the levels of ROGs and particulates emitted from the die casters are old and inadequate (based on tests done in the mid-90s), and Kipp has added many more die cast machines since the time they were developed. So the estimated levels of ROGs and particulates on inventories are likely too low. (Several years ago, Kipp raised its stacks higher in order to disperse these compounds, associated with the “waxy/oily/burnt” smell nearby residents have complained about for years, further out into the community. Given this, it defies common sense (and science) to assert–as Mr. Koblinski did on March 19–that none of the PAHs and other contaminants found in nearby residential soils are from the facility. The elaborate (but problematic) statistical analyses by Kipp’s consultants, and comparisons to background samples obtained by government agencies (which certainly included some of Kipp’s PAHs, dispersed widely around the community via taller stacks) do not prove that none of the PAHs and other contaminants found in soils offsite came from Kipp).

As a result of inadequate reporting and data gaps, it is difficult for citizens or workers to track what Kipp is really emitting outside or inside the plant. Efforts by the Madison Department of Public Health (now called Public Health Madison Dane County, PHMDC) to assess exposures in the Kipp neighborhood were aborted because of limited or no air monitoring. Ultimately the agency concluded in its 2001 report that there were too many data gaps to draw any conclusions, and recommended more air monitoring. Unfortunately, 13 years after this report was written, no further air monitoring around Kipp has been done.

What are workers breathing inside Kipp?

Many of the compounds emitted from Kipp’s stacks are likely found to some degree inside the factory, where workers are exposed to a number of them at the same time. Unfortunately, even less information is publicly available about chemical exposures inside Kipp than is available about outdoor emissions.[18] Regardless, several of the compounds listed above and known to be emitted from, and found inside, aluminum die casting facilities, can aggravate respiratory problems and a range of other health effects. Kipp workers have also been breathing unknown levels of toxic vapors from beneath the plant, which include tetrachloroethylene (PCE), trichloroethylene (TCE), vinyl chloride (VC), and other VOCs known to aggravate respiratory problems and headaches. Most of these chemicals are also associated in scientific studies with a number of serious long-term health problems, including cancer.

Next we discuss some of the above compounds that are most likely aggravating respiratory and other acute problems among workers. We discuss the sparse data available from monitoring inside of Kipp, what it can (or cannot) tell us about exposures to Kipp workers, and government agency actions (or lack thereof) related to Kipp workers’ health and safety.

If you have read this far, and are interested in learning more about what we have learned, please email us at info@mejo.us.



[1] The talk was most likely written by Kipp’s law firm, Michael Best & Friederich

[2] These numbers are approximate (possibly underestimated) due to gaps in records; they also don’t include Fire/EMS calls to the Sun Prairie facility.

[3] While some of these recorded calls were false alarms, we have heard that many times there are close calls (near-miss accidents and fires, etc) for which nobody ever calls the Fire Department, in part because management wants to keep the official fire call record as low as possible. Consequently, the official number of calls in records is likely an underestimate of the actual number of accidents, fires, and worker illnesses.

[4] Kipp’s lowest-end manufacturing workers, contractor cleaning employees, and temporary workers include ex-offenders, homeless people, and a significant proportion of minorities. Sadly, statistics show that these groups are likely to be much less healthy than more privileged people—making them even more vulnerable to health problems from exposures to contaminants in Kipp. Many also lack health insurance. This is a significant environmental justice issue that has been completely ignored by Kipp and the government agencies responsible for protecting public health in Madison/Dane Co. and Wisconsin.

[5] A fire on August 1, 1992 sent four firefighters to the hospital after they inhaled noxious fumes. The Aug. 2 1992 Madison newspaper article on this fire, titled “Molten Flames,” says that the building filled with smoke and noxious fumes.

[6]  He only found out about it after coming across it on the MEJO website.

[7] Some of the precautions EPA recommends when excavating contaminated soil: “Handling contaminated soil requires precautions to ensure safety. Site workers are trained to follow safety procedures while excavating soil to avoid contact with contaminants…Site workers typically wear protective clothing such as rubber gloves, boots, hard hats, and coveralls. These items are either washed or disposed of before leaving the site to keep workers from carrying contaminated soil offsite on their shoes and clothing…Workers monitor the air to make sure dust and contaminant vapors are not present at levels that may pose a breathing risk, and monitors may be placed around the site to ensure that dust or vapors are not leaving it. Site workers close to the excavation may need to wear “respirators,” which are face masks equipped with filters that remove dust and contaminants from the air…

[8] Now the new machinery is installed, the dirt was hauled away, and the floors cleaned up. The area was re-painted and is clean and shiny.

[9] From what we understand (not having seen this document), the last inspection in Kipp for insurance purposes was 3 years ago.

[10] Mr. Koblinski said in his March 19 presentation that the company’s current priorities include “managing health risks to employees” and “communicating openly with the neighborhood.” If this is the case, the company should openly share the health and safety assessments done inside the factory by insurance companies and other third parties. If they are unwilling to share these assessments, what are they hiding?  On the other hand, if the assessments are comprehensive and state of the art, and show that the factory is safe, that would be reassuring to workers and the neighborhood. So why won’t Kipp share them?

[11] In the weeks just before this article was written, residents near Kipp have reported increased odors from the plant, including a particularly acrid smell that seems new to them.

[12] Dalquist and Gutkowski, 2004

[13] Again, see previous articles

[14] In Wisconsin, industry (likely including MKC) lobbied to not report certain emissions on public inventories at all unless they were modeled at over NR 438 levels. See previous article describing some of these issues, particularly as they relate to dioxins and chlorinated compounds, among Kipp’s most toxic emissions.

[15] Given that Kipp purportedly no longer uses tetrachoroethylene (PCE) (and it is not clear whether they still use trichloroethylene, TCE), it is unknown whether Kipp has or still does emit these compounds from its stacks; PCE, TCE, and their breakdown product, vinyl chloride, have never been tested for in Kipp’ air stack emissions. They are being emitted (and monitored) from soil vapor extraction (SVE) systems on the site. It’s unknown what compounds Kipp used to replace PCE—and what kinds of emissions might be associated with these replacement chemicals

[16] MEJO has asked government agencies several times what Kipp replaced PCE/TCE and PCBs with, but have never received answers.

[17] Levels of ROGs listed on Kipp’s inventories have increased significantly in recent years, from 17.4 tons in 2008  to just over 26  tons in 2012 (2013 and 2014 levels are not available yet). Of course, these levels do not include VOCs being emitted from vapor extraction systems all over the site.

[18] Air monitoring in aluminum die casting facilities has been relatively scant—in part due to die-cast industry’s competitiveness, success in withholding proprietary information about the chemicals they use, and resistance to any monitoring in their plants.

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So Sorry, DNR! Here’s the full transcript of the Jan. 29 2014 MEJO-DNR meeting

So Sorry, DNR! Here’s the full transcript of the Jan. 29 2014 MEJO-DNR meeting

(MEJO President, Dr. Maria Powell)

In a meeting on March 21st, two DNR managers and two DNR lawyers scolded MEJO President, Dr. Maria Powell, for audiotaping the January 29 meeting with four DNR staff and posting only a partial transcript of the meeting. DNR legal counsel, Lacey Cochart, asked that we post the entire meeting transcript.

Honoring this request, MEJO staff (who are not professional transcribers) spent nearly 14 hours transcribing the tape of the entire meeting, which is here. The one hour, 20 minute long meeting included DNR’s explanation for their threat of $700 fees to MEJO to ask further questions, as well as their responses to MEJO’s questions about their open records policy, decisions about posting public comments, environmental justice policy, assessment of Kipp worker exposures, assessment of contaminants in air emissions, and more. Enjoy!

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“Mother Nature, though wounded, begins to take care of it,” says polluter

“Mother Nature, though wounded, begins to take care of it,” says polluter

At a March 19 public presentation, the president of Madison-Kipp Corporation described various pollution remediation actions that the aluminum parts manufacturer is belatedly being forced to do by the Wisconsin DNR, as a result of decades of citizen complaints and recent lawsuits. A sparsely attended meeting at the Goodman Community Center, adjacent to Kipp, was the setting for the hour long presentation by its CEO, Tony Koblinski.

Describing the expansive Kipp PCE  pollution plume that extends underground through the Atwood neighborhood, Koblinski assured attendees that over time “Mother Nature, though wounded, begins to take care of it.”

About a dozen public officials from various state, county and city agencies sat at tables in the back, but did not speak even once during the meeting (though many of Mr. Koblinski’s statements were unsubstantiated by the evidence and/or incorrect). We have never seen a neighborhood meeting to address environmental and human health concerns completely turned over to the polluter, as was done at this meeting. Now we know what it looks like. It was very disturbing.

MEJO videotaped the event, over the objections of Koblinski who apparently has never been to a public meeting (where this is commonplace). Click the links below to watch the video, which is being presented as part of the public record regarding this ongoing saga of a loud and smelly old factory, a century of pollution, and a residential neighborhood.

Part 1

Part 2

Part 3

Part 4

[This is the entire presentation, except for few seconds at the beginning that we missed and the times when we switched out full video cards.]
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Kipp Offers Water Utility Some Advice: Run Olbrich Well 24/7!

Kipp Offers Water Utility Some Advice: Run Olbrich Well 24/7!

In a February 26, 2014 email Madison-Kipp Corporation advised the Madison Water Utility to pump the Olbrich Well (Well 8) full-time, after the Water Utility Board asked for assurance from the Wisconsin DNR that Well 8 will not be impacted by Kipp’s contamination plume.

Apparently the Water Utility is considering using Well 8 full-time again, despite knowing that the well is very likely connected to the upper aquifer, making it highly vulnerable to the significant contamination spreading from Kipp. This information, found in Kipp’s consultant report on DNR website, flies in the face of repeated assurances from the Madison Water Utility and Kipp over the last several years that Well 8 is protected from Kipp’s contamination by the Eau Claire shale layer. See footnote for more information and a link to the report.

In the Feb. 26 email, Kipp’s consultant, at the request of Kipp CEO Tony Koblinski, asserted that “all of the data, information, and best available science indicate that Unit Well 8 will not be impacted by PCE in groundwater at the Madison Kipp site if Well 8 operates 24/7.” In support of this, among other things, Kipp claims that “the vertical extent of PCE has been delineated at the Madison Kipp site,” “is not deeper than 170 feet,” and the “the PCE plume has stabilized and is no longer expanding.”

These claims are completely unsubstantiated by evidence. The vertical and horizontal extents of the Kipp plume have never been fully delineated, as this memo describes, and communications among government officials also state. Since nobody knows how deep and wide the Kipp plume really is—because there hasn’t been enough testing— it is impossible to verify that the plume is “stabilized” and “no longer expanding.”

This raises many questions. One big one: Why would it be to Kipp’s advantage to pump Well 8 full time? We speculate on this and other questions in an upcoming post. Please send your thoughts on this to info “at”mejo.us

*************************

The Well 8 log is in the last 3 pages of this report. On p. 9 of the report, it states:

“The City of Madison drinking water source is groundwater from various sandstone bedrock formations. Municipal Unit Well 8 is the closest municipal well to the Site and is approximately 1,400 feet southeast of the Site (Figure 1). Municipal Unit Well 8 is cased to 280 feet bls, below the Eau Claire shale aquitard, and is an open bedrock well across the Mount Simon Formation from 280 to 774 feet bls (McCarthy, 1945). According to the Unit Well 8 boring log (Appendix C), dynamite shots were used in a nearby test borehole at depths of approximately 380 feet, 430 feet, 480 feet, and 530 feet to fracture the bedrock between the test and Unit Well 8 borehole to increase the specific capacity of Unit Well 8. After the boreholes were connected by fracturing the bedrock, Unit Well 8 was tested at a pumping rate of approximately 1,965 gallons per minute with 65 feet of drawdown, yielding a specific capacity of approximately 30 gallons per minute per foot of drawdown.”

The “test well” they are referring to above is not cased through the Eau Claire shale. This means it is open to the upper aquifer. Because the test well and the production well have been connected (via dynamite shots), essentially the two wells are connected. In sum, this means that Well 8 is very likely connected to the upper aquifer through the test well hole. Government officials at city, county, and state agencies have known about this for some time, but have never shared this information publicly.

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Medical researchers say brain disorders tied to industrial chemicals

Medical researchers say brain disorders tied to industrial chemicals

“Children worldwide are being exposed to unrecognized toxic chemicals that are silently eroding intelligence, disrupting behaviours, truncating future achievements and damaging societies” according to a new Lancet Neurology article. Also read more here.

In other words, toxins emitted from Kipp and other industries have significant long-term and irreversible effects on our children, our educational system, and our whole society. Here’s the abstract from the Lancet Neurology article by Dr. Grandjean and Dr. Landrigan:

“Neurodevelopmental disabilities, including autism, attention-deficit hyperactivity disorder, dyslexia, and other cognitive impairments, affect millions of children worldwide, and some diagnoses seem to be increasing in frequency. Industrial chemicals that injure the developing brain are among the known causes for this rise in prevalence. In 2006, we did a systematic review and identified five industrial chemicals as developmental neurotoxicants: lead, methylmercury, polychlorinated biphenyls, arsenic, and toluene. Since 2006, epidemiological studies have documented six additional developmental neurotoxicants—manganese, fluoride, chlorpyrifos, dichlorodiphenyltrichloroethane, tetrachloroethylene, and the polybrominated diphenyl ethers. We postulate that even more neurotoxicants remain undiscovered. To control the pandemic of developmental neurotoxicity, we propose a global prevention strategy. Untested chemicals should not be presumed to be safe to brain development, and chemicals in existing use and all new chemicals must therefore be tested for developmental neurotoxicity. To coordinate these efforts and to accelerate translation of science into prevention, we propose the urgent formation of a new international clearinghouse.”

EIGHT of the chemicals highlighted as the most damaging to the developing brain are known to be emitted from Madison Kipp Corporation and/or have been found in soils, groundwater and/or air at the site. This factory is just feet away from homes, schools, daycare centers, and a community center that focuses on programs for low income and minority children.

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High Levels of PCBs Being Excavated from Kipp’s Floors—Are Workers Protected?

High Levels of PCBs Being Excavated from Kipp’s Floors—Are Workers Protected?

(Two Kipp Workers, photo by John Hart, Madison.com). According to a recent letter  from Kipp to the DNR, Kipp has been excavating inside the factory, and finding PCBs in concrete floors hundreds of times above the residual contact levels (levels considered safe for direct contact) in some places. This is not surprising, given that up to 20,000 ppm PCBs have been found beneath the factory floor, as we reported in our previous post. All of these PCB contaminated materials are also very likely contaminated with dioxins—among the most toxic chemicals ever studied (significantly more toxic than PCBs).

This raises more questions for our “Unanswered Questions: Madison-Kipp Unbound” series: What is being done right now to protect Kipp’s non-unionized workers as these highly PCB contaminated materials are being excavated? What machines (referred to in the letter) are being installed? Who is doing the excavation? What is being done—and has been done in the past—to protect workers from the myriad toxic contaminants used at Kipp, emitted into factory air, and sloshed around on the floor? Are tetrachloroethylene (PCE) and other toxic vapors seeping into the plant from the giant contaminant plume below the floor?  Has anyone measured? What about the workers who clean Kipp? Are they and other workers aware of the polychlorinated biphenyls (PCBs) and other toxins in floors, walls, and air? Do they have adequate protective gear? What are Kipp Corporation and the relevant government agencies doing to assure that workers are not exposed to toxic contaminants?

Are Kipp Worker Exposures Even on Radar Screen of Government Agencies…?

Madison Kipp’s non-unionized workers—which include many minorities, as well as some ex-offenders—are among the most exposed to the factory’s toxic pollution. Kipp also hires a number of low-wage LTEs (limited term employees) during busy times, and at times employs homeless people.[1]Various companies are contracted to clean Kipp and remove wastes; cleaning Kipp and removing wastes likely involve exposures to a stew of toxic contaminants.[2]

Yet even as PCE, PCB, TCE (trichloroethylene), PAHs (polycyclic aromatic hydrocarbons), vinyl chloride, dioxins, heavy metals, and myriad other contaminants have been measured in soils and groundwater under Kipp, and/or emitted into factory air and from stacks, local and state government agencies and elected officials apparently are not very concerned about the health and safety of the manufacturing workers at the plant. In our reviews of thousands of pages of documents and communications from local and state agencies, we have not seen anything about assessing exposures to Kipp factory workers, assuring that they are protected, or communicating with them about potential exposures in and around the plant.[3]  Even public health agencies don’t seem to be concerned about workers’ health and well-being at all—or if they are, it is not evident anywhere.

What about the U.S. Occupational Safety and Health Administration (OSHA), which has an office in Madison? It’s our understanding that OSHA doesn’t investigate workplace exposures unless there is a formal complaint. While OSHA has been in Kipp several times in the last 10-15 years to investigate a number of serious worker accidents, and has issued numerous citations for significant safety violations (see next story), we have found no evidence that OSHA staff have ever investigated worker exposures to PCEs, PCBs, or any of the other highly toxic contaminants found at Kipp in recent years—nor has OSHA been involved in helping to develop strategies to protect workers from harmful exposures to these contaminants .[4]

When MEJO met with four DNR managers on Jan. 29 2014, we asked whether they had ever contacted OSHA and they said “no”—but “they will.” Shouldn’t the DNR and its city/county and state health agency collaborators have contacted OSHA many years ago, especially as the enormous plume of toxic compounds was documented under the plant, with a high potential for vapor intrusion into the factory (however, see footnote #3)? Why haven’t they contacted OSHA to get guidance on assessing worker exposures and ways to best protect workers as toxic materials are excavated all around the plant? Do DNR staff have training in assessing workplace exposures to dusts and particulates, vapors, VOCs, PCBs? Are they industrial hygienists? Is the EPA, involved with the PCB portion of the Kipp investigation, assuring that workers are protected from PCB exposures?

Of course, Kipp’s non-unionized manufacturing workers are very unlikely to complain to OSHA or anyone, for a number of reasons. Most are unaware of the toxins around them and/or serious implications for their health and their children’s health (if they are women of childbearing age). Even if they are aware, they are very unlikely to complain to superiors or say anything publicly, because they do not want to jeopardize their jobs.  Not being unionized, they have no organization to protect and represent them in complaints against their employer. They are probably very grateful to have a job—any job. Some, like homeless people and ex-offenders, have few other choices.

Sadly, this scenario fits a classic pattern of environmental injustice: the most vulnerable people—also the least privileged, least likely to have the capacities and resources to protect themselves, and with fewer alternatives available to them as far as work—are ignored by government and other powers-that-be.

Why have government agencies, public officials, media, and even neighborhood groups not raised questions about the health and safety of Kipp’s workers? With jobs and economic growth currently the top priority on all sides of the political spectrum, public officials on the left and right are reluctant to do or say anything that might threaten jobs.

MEJO does not want Kipp workers to lose their means of supporting themselves and their families. But they deserve safe and healthy work that will not increase their (or their children’s) risks for serious health problems—problems that will likely create even more socioeconomic challenges for them in the future.

Again: What are Madison Kipp, responsible government agencies, and elected officials doing to assure that Kipp workers are protected from toxic exposures?

To be continued in next post…

People out there–comments, answers, questions, corrections? Please send to: info@mejo.us. THANKS!!!


[1] MEJO members know people who worked at Kipp while homeless (though they are still homeless, they no longer work there). Sadly, one said he couldn’t keep the job because he kept falling asleep at work. Another recalled sloppy practices in the plant. See the next post…

[2] MEJO members have talked to people who cleaned at Kipp and suffered health effects while there.

[3] Ironically, a recent Kipp consultant report revealed that Kipp would be assessing vapor intrusion only in the office portions of the plant. Why not the manufacturing portions? Are they concerned about Kipp’s managers and administrative staff but not the manufacturing workers, cleaning contractors, and other temporary workers?

[4] In 2011, OSHA did a very limited one-time assessment of aluminum dust.

 

 

 

 

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20,000 ppm PCBs under Kipp? No Worries ! “Just Ordinary Dirt,” says Kipp CEO

20,000 ppm PCBs under Kipp? No Worries ! “Just Ordinary Dirt,” says Kipp CEO

(Kipp’s CEO, Tony Koblinski, in Kipp’s corporate offices, photo from Madison.com)

In a June 19, 2013 letter to the Wisconsin DNR (first obtained by MEJO in January, 2014), the U.S. EPA stated that it informed Kipp in a meeting on April 10, 2013 (see powerpoint presented at that meeting here) that the PCB levels of up to 20,000 ppm found in soils under the factory are “too high to remain in place” because “unacceptably high exposure levels would exist if institutional controls and/or engineered barriers fail.”

The DNR’s non-industrial residual contact level (RCL) for PCBs—the level above which human contact is considered unsafe— is .222 ppm. In other words, the levels of PCBs found under Kipp are up to nearly 100,000 times above the level considered safe for human contact.  Apparently EPA risk assessors don’t think leaving these PCB-laden soils under the factory is an acceptable option, because if caps or barriers constructed to contain the soils fail, people could be exposed to extremely harmful levels of PCBs.

Soils behind some homes on Waubesa Street, just feet away from the PCB contamination under Kipp, were also contaminated with PCBs  above RCLs. Before there was any public awareness or discussion about this problem, Kipp quietly notified people with contaminated soils behind their homes, and quickly moved to excavate them. Neighbors observed that little to nothing was done to protect residents from PCB dust and runoff during excavation in June.  Getting rid of the evidence as fast as possible, perhaps?

Most appallingly, during excavation—well after Kipp had been notified of the PCB problem by the EPA— Kipp CEO Tony Koblinski had the gall to tell a concerned neighbor that the soil being hauled from people’s yards was “ordinary dirt.” When asked about the PCBs in the soil, he said “you don’t know that” and “I don’t know that.” Unbelievable! Watch it here.

Which brings us to….

UNANSWERED QUESTIONS 

As we described in an earlier post— the understaffed and overwhelmed DNR told MEJO they can’t be burdened with further questions from us (and may charge us $700 if we persist in asking them). We turned to Ask.com, but it didn’t have answers either. So we will turn to you—citizens, the public, anyone out there—for help with our questions.

Any answers to these questions?

What is the source of the PCBs under the Kipp plant and behind the homes on Waubesa Street?

A Kipp consultant report (see page 2) says that there was a road between the Waubesa Street homes and the factory at one time, and implies that perhaps it was coated with PCB oils and that may be the source of PCBs under the plant. If that’s the case, why did Kipp only share first this information in late 2013? Why did the DNR not post the report with this information on the Kipp website until months after it was released, and only after MEJO found it in the DNR files and asked that it be posted (in Dec. 2013)?

Why did DNR tell MEJO on Dec. 4, 2013 that “the source of the PCBs is unknown”—when the Kipp consultant report with the statement about the road was submitted to the DNR on Sept. 30, 2013? Do Kipp and the DNR not want the public to know about this old road? Why not?

When did Kipp first do PCB testing under the factory? How many samples were taken? Where exactly?

What is the range of PCB levels being found beneath the factory? When did the DNR and health agencies first see PCB data from under the factory?

Before being taken away to a landfill, PCB contaminated soils were stored on the north side of the Kipp parking lot for various periods of time. Were signs posted there to keep children away? Did Kipp comply with regulations (NR 714) regarding signage at contaminated sites?

Were adequate barriers placed over/around the piles of contaminated soils to prevent dust from flying up and runoff from going into the storm drains, gutters, and the nearby raingarden (found to be very contaminated with PCBs in 2012)?

Why was there no public meeting to discuss these important PCB results, with serious implications for the neighborhood, the broader community, and the City of Madison?

Why did DNR staff intentionally withhold this information from a journalist who contacted them with questions about the PCB excavations in May 2013?

The DNR told us they are meeting with SASYNA regularly. Have they discussed the PCB levels under the plant with them?  If not, why not? If so, why hasn’t SASYNA shared it more widely with the community?

Were neighbors on Waubesa Street ever notified of high levels of PCBs under the plant feet from their homes—and the future implications they could have for them? (e.g., more digging behind their homes, potential exposures for them and their children, etc.)?

What is the status of the PCB testing under Kipp currently? Will the public ever see the full results?

What is Kipp planning to do about the PCBs under their plant?

What about Kipp’s non-unionized workers? Is anyone assessing their exposures to PCBs and the many other toxic compounds being found in and under the plant? (See upcoming posts)

People out there—any thoughts? Further questions to add? Please send them to info@mejo.us

 

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DNR Too Busy to Answer Questions About Madison-Kipp. Can Anyone Out There Help?

DNR Too Busy to Answer Questions About Madison-Kipp. Can Anyone Out There Help?

For several years, MEJO has been asking the Wisconsin DNR questions related to Madison-Kipp Corporation’s toxic pollution. Last December, Remediation and Redevelopment staff threatened us with a $700 fee to ask further questions—citing this policy. The DNR email message and our response are here.

On January 29, 2014, we met with South Central Region Bureau Director Mark Aquino and three of his staff to discuss their rationale for applying this policy— clearly intended for industries and facilities that have released toxic pollution—to citizens asking questions about the effects of this pollution on people and the environment.

They explained that the DNR is too busy to answer further questions. They have much more important work to do. They reminded us that we can review online and hard copy files any time to search for answers to our questions. Here is a partial transcript of what they said.

Given this, we appreciate the generosity of DNR to allow four agency managers to take an hour and a half to meet with us free of charge. This probably cost taxpayers about $300, so the DNR could have raised $400 ($700 technical assistance fee minus $300 actual costs) to reduce the state’s debt—but they didn’t; we’ll be eternally grateful). But we have learned that these public servants do not want to be burdened by further questions about Kipp.

This leaves us with a problem. Many of our questions have never been answered. New questions are arising all the time as monitoring data is released and we review documents. We have reviewed thousands of pages of documents and still not found answers. We have spent entire days going through jumbled, unorganized files at state and local government offices looking for information or documents we never found. Some critical documents—that we know exist—don’t seem to be in the files at all. Others seem to have disappeared from the files over time—we saw them once, they were gone the next time.  Aquino assured us that these files were the “official repository,” so the disorganization of the files, and ease by which documents come and go, are disconcerting.

Further, many of our most important questions cannot be answered by reviewing documents; we need answers from actual people—in particular, government agency staff who make decisions related to Kipp pollution.

But rather than further burden the understaffed and overwhelmed DNR, we have decided to try other strategies to address our questions. We turned to Ask.com, but it didn’t have answers either.* So we will turn to you—citizens, the public, anyone out there—for help with our questions. We are launching a new series, “Unanswered Questions: Madison-Kipp Unbound—How a Polluter Gets Its Way” in which we will post questions that we would have sent to DNR and other government agencies—or have sent them in the past but not received adequate (or any) answers. We hope someone out there can help us!

Watch for Part 1 of “Unanswered Questions,” coming soon….

 

*Ask.com directs you the DNR Brownfields web pages for Kipp, which don’t have the answers, of course.

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DNR Now Charging $700 to Answer Questions?

DNR Now Charging $700 to Answer Questions?

The DNR just doesn’t like to answer questions about Madison-Kipp Corp. MEJO has experienced the art of the “non-answer” answer from DNR for years, but now it has gotten to the point where DNR not only won’t answer questions, they want to charge $700 if we bother them again with questions.

 

——– Original Message ——–

Subject:

Re: followup questions re Kipp

Date:

Thu, 05 Dec 2013 11:44:26 -0600

From:

Maria Powell (MEJO) <mariapowell@mejo.us>

To:

Hanefeld, Linda S – DNR <Linda.Hanefeld@wisconsin.gov>, Schmoller, Michael R – DNR <Michael.Schmoller@wisconsin.gov>, JHausbeck@publichealthmdc.com <JHausbeck@publichealthmdc.com>, Nehls-Lowe, Henry L – DHS <Henry.NehlsLowe@dhs.wisconsin.gov>, Walsh, Patrick – LEGIS <Patrick.Walsh@legis.wisconsin.gov>, Rep.Taylor@legis.wisconsin.gov <Rep.Taylor@legis.wisconsin.gov>, Rummel, Marsha <district6@cityofmadison.com>

CC:

Weihemuller, Wendy – DNR <Wendy.Weihemuller@wisconsin.gov>, Giesfeldt, Mark F – DNR <Mark.Giesfeldt@wisconsin.gov>, Aquino, Mark D – DNR <Mark.Aquino@wisconsin.gov>, Miller, Mark <Mark.Miller@legis.wisconsin.gov>, Rep.Sargent@legis.wisconsin.gov

Linda:

Thanks for the responses. Unfortunately, most of your answers are evasive or so vague they are meaningless. We have indeed asked some of these questions before, but some were never answered and/or answers were vague. They were not detailed technical answers. We are of course aware of the documents on the DNR website; we have read most of them and they do not fully or adequately address our questions–in fact, documents posted there raised these questions in the first place.

Now, you seem to be telling us at the end of the email below that we have to pay the DNR $700 if we want any further responses to our questions (presumably this is what you mean by “additional technical assistance”).  This is the first time in my decades of environmental work I have heard of citizens being asked to pay huge fees to government agencies just for answering questions. Is this part of the DNR’s new “customer service” approach?

Are Madison Kipp Corporation and other industries also required to pay DNR $700 every time they want “technical assistance” from the agency? We know Madison Kipp representatives have been at the table for years with the DNR and other state agencies discussing legal, regulatory and technical issues and collectively making decisions–including  throughout the recent lawsuits. Do they pay for this “customer service,” or “technical assistance”? If I and other citizens want to meet with you in person to discuss our questions, can we do so? Do we have to pay a fee for that?

Please clarify. Hopefully, you will do so without us paying you several hundred dollars first. We’d like to better understand our roles as citizen “customers” of our government public servants.

Maria

On 12/4/2013 3:46 PM, Hanefeld, Linda S – DNR wrote:

Greetings, Maria,

 My responses are included in your text below.

 Linda

From: Maria Powell (MEJO) [mailto:mariapowell@mejo.us] Sent: Friday, November 22, 2013 9:27 AM
To: Hanefeld, Linda S – DNR; Schmoller, Michael R – DNR; JHausbeck@publichealthmdc.com; Nehls-Lowe, Henry L – DHS; Walsh, Patrick – LEGIS; Rep.Taylor@legis.wisconsin.gov; Rummel, Marsha
Subject: Re: followup questions re Kipp

Hello:

Will anyone be able to address the questions below? Please let me know.

Thanks,
Maria

On 11/14/2013 12:25 PM, Maria Powell (MEJO) wrote:

Linda et al:

We have now read through a few more of the Kipp documents released on Nov. 2, and we have some follow-up questions:

-Has Kipp provided the “updated conceptual site model” that DNR asked for by Sept. 30 in the June DNR letter? If so, can we access it? We have been asking for Kipp’s CSM for two years.

Kipp has provided information about their site conceptual model in several documents.  The complete file is available for review at the South Central Regional Headquarters building at 3911 Fish Hatchery Road, Fitchburg.  Please contact Wendy Weihemuller (608-275-3212) to schedule a review time if needed.

-As you know, EPA guidances recommend evaluation of the vapor intrusion pathway at buildings located within 100 feet laterally or vertically from a subsurface VOC source “of potential concern.” Based on the most recent data, does Goodman Center still not meet these criteria?

The Department has answered this question in previous correspondence.   The DNR has concluded that vapor issues for the neighborhood have been adequately investigated/addressed.  Please use the link below to access the document summarizing vapor sampling results for the Kipp neighborhood.

http://dnr.wi.gov/files/PDF/pubs/rr/RR931.pdf

-What is the rationale for the location of the water table well on the Goodman property?

To define the extent of groundwater contamination at the water table in that direction.

-What is/are the source(s) of the PCBs on the Waubesa side of Kipp?

The “source” of PCBs is unknown, although DNR believes activities at Kipp have contributed to the PCB contamination there.

-Why is indoor air sampling only being done in the office portions of MKC, and not the rest of the plant?

DNR is determining whether the is the potential for vapor intrusion issues at the facility. The office portion of the facility seems like a logical place to start.

-Has any groundwater testing directly to the south of Kipp been ruled out? If so, on what basis?

 Based on the data collected to date, we feel we know enough about groundwater in that direction.

Also, the June letter asked Kipp to conduct soil sampling for VOCs and PCBs in the raingarden. Yet Arcadis had already tested the raingarden area on 6/21/12, and data from one boring done then was included in the raingarden document released on Nov. 2. Was the DNR not aware of this data when they wrote the June letter? Or is the DNR asking for further testing beyond what was done in June  2012? Please clarify.

The DNR was aware of the June 2012 data.  Additional sampling was required to determine nature/extent of that contamination.

We will probably have more questions once we have read through all the documents in more detail.

If you find you need additional technical assistance, please be aware that there is a $700 fee for any requests for detailed responses similar to those you have been receiving (see chapter NR749, Wisconsin Administrative Code, for more details:  https://docs.legis.wisconsin.gov/code/admin_code/nr/700/749.pdf  ).  DNR has made many documents regarding this case available both on-line at:  http://dnr.wi.gov/topic/Brownfields/kipp.html  , and at the local library.  As mentioned above, the complete file can be reviewed by appointment.

Thanks in advance for your responses,

Maria

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PCEs with your Pie, Anyone? Toxic Plume Under Goodman Center Still Ignored…

PCEs with your Pie, Anyone? Toxic Plume Under Goodman Center Still Ignored…

A couple weeks ago, I had lunch with a friend in the Ironworks Café at the Goodman Community Center. The food was delicious and the servers were helpful and friendly.  Pre-school age children were laughing and playing in the playground. Teenage kids were taking plants from the raised-bed gardens just outside the café to the compost pile. We agreed that Goodman’s gardening and food service programs for teens, and other programs for children, are impressive and commendable.

But while munching on my sandwich, I remembered that the highest levels of PCE found on the Goodman property before redevelopment (in 2001) were in soils just a few feet outside my window, under the outdoor cafe. PCE over the enforcement standard level was also found in the groundwater below where the outdoor café is now. It’s not clear how deep this contamination was at the time.

In April 2013, Madison-Kipp Corp. consultants released a map of a huge plume of much higher levels of PCE and other volatile organic compound (VOC) contamination beneath the Goodman property. Given that the highest levels of groundwater contamination at Madison-Kipp are at the northern part of the property, just across the bike path from the center (a few feet from the raised bed gardens), this is not surprising.

The top layers of contaminated soils at Goodman were removed and replaced before the center was opened, but the contaminated groundwater is still there. What levels of PCE and other VOCs are beneath the center now? How far below? Is the plume releasing toxic vapors into the Goodman Center? Nobody knows.

And apparently, nobody wants to know. This month the DNR released documents showing that the agency is finally asking Kipp to sink a shallow well on the Goodman property. But why will this well be located way out in the parking lot area? Toxic vapors released from any shallow groundwater contamination there will mostly dissipate in outdoor air. Whether contamination is or isn’t found there, this will not tell us much about exposures to people inside the Goodman Center. If there are PCEs and other toxic VOCs in shallow groundwater beneath the center, vapors released from this water will likely concentrate beneath the center—and then seep up into the building. Testing way out in the parking lot will tell us little to nothing about exposures to people in the center.

Yet again, we ask: Why are potential toxic exposures to the most vulnerable people—children and seniors in the Goodman Center—being ignored? Why have our questions about these potential exposures been repeatedly ignored or dismissed (and at times even ridiculed) by public health officials and Goodman leaders? Since the significant and widespread PCE and PCB contamination at Kipp was uncovered in 2011-2012, to our knowledge not even a single test has been done at Goodman to see if children there are exposed to Kipp’s contaminants in soil, groundwater, and/or air. Why not?

Perhaps neither Madison-Kipp nor Goodman leaders want to open up this politically messy can of worms—especially since they have been in bed together for years. Madison-Kipp has supported Goodman in a variety of ways, financial and otherwise, since the center’s inception. A year before the center opened, in a May 2007 letter to the Madison Planning Commission, CEO Reed Coleman bragged that “Madison-Kipp is a proud supporter of the new Goodman Atwood community center. What an asset it will be to the entire east side. Madison-Kipp is committed to helping with the success of the new center and have lent our support in numerous ways…” (Ironically, he then goes on to offer parking in the Kipp lot, which we now know was coated in PCBs for years, for Goodman Center users).

While things seem to have been cozy historically between Madison-Kipp and Goodman, opening up the can of worms related to Kipp’s toxic contamination plume under Goodman could turn very ugly, with former bedfellows quickly becoming enemies. Though Goodman closure documents explicitly state that Kipp is the source of the PCEs in the groundwater under the Goodman property, if this issue was opened up again, Kipp would likely blame past industrial activities on the Goodman property (e.g., Kupfer Ironworks). In a March 2012 email to the DNR and other public officials, Kipp attorney David Crass resisted DNR’s request that soil vapor probes be placed on the bike path north of the Kipp property,[1] noting that “…historic PCE use has been documented at the Goodman Center property, which will lead to questions regarding origins of any results and will infect any future decisionmaking regarding the results.”

Hmmm. So maybe it’s to both Goodman’s and Madison-Kipp’s benefit to stay mum and resist testing, and deny any public health risks at Goodman—regardless of the source of the pollution—rather than face the uncomfortable prospect of intense political, legal, and financial battles with former bedfellows?  In a twisted way, perhaps Kipp and Goodman are protecting each other?

What about government officials? Why are they so adamantly declaring that there are no exposures whatsoever in the center, though there haven’t been any tests? It seems they are either woefully unaware of the current scientific research and EPA guidances on PCE vapor intrusion (which indicate that vapor intrusion should be investigated in the Goodman building), or they are totally ignoring them. Of course, they approved the re-development of the Goodman Center in 2008 apparently without considering vapor intrusion, even though extremely high levels of PCE and other VOCs had already been well documented on the northern part of the Kipp property (just feet away from the Goodman building) beginning in 1994. If tests now were to show that vapors from the plume under Goodman are leaking into the center (and/or that children there are exposed to other toxic contamination from Kipp), blame for the lack of oversight that led to these exposures would be directed at them. Maybe not testing at all is way to avoid this uncomfortable situation?

So if our suspicions are correct, Madison-Kipp, Goodman leaders, and government officials alike are, ironically, protecting each other (intentionally or not) by putting their concerns about politics, money, and reputations above assessing risks to children and seniors, who apparently don’t matter in their political games. How unethical is this?

Note to readers: We would love for our speculations above to be wrong. If anyone out there wants to disagree—or better yet, send information disproving anything said above—please do so! Email info@mejo.us



[1] Vapor probes were eventually placed along the south edge of the bike path and results from 3/30/12 and 10/26/12 showed concerning levels of PCE and several of its breakdown products at the probe right across from the circle gathering area at Goodman. If these levels were under a building, they would likely be a problem as far as vapor intrusion inside the center. But it seems nobody will test inside—or even anywhere near—the center.

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